Privacy notice

In short

Lily&Luna helps you with paperwork, deadlines and practical steps in Spain. To do that we have to process information about you. We collect only what the service needs, we do not sell anything on, and we do not use your data for advertising.

You can see, correct, download or delete what we hold about you at any time.

Who is the controller

The controller is the service owner named on the support page. That is who you contact about anything in this document.

What we process

Account details. Your name and email address. A password is optional: if you have set one, we store an encrypted fingerprint of it, never the password itself — and if you have none, there is no fingerprint with us at all.

If you sign in with Google, Apple or Vipps, we store which provider you used, the internal user ID that provider gives us, the email address the provider gave when you linked the account, and when the link was made and last used. We store no tokens from the provider, and we cannot fetch anything at all from them on your behalf. If you choose Apple's "Hide My Email", we treat the relay address (@privaterelay.appleid.com) like any other email address.

A sign-in you have started but not completed stays with us for at most fifteen minutes: which provider you chose, the user ID, the email address and the name the provider gave, and a fingerprint of our own one-time handover ticket. The provider's tokens are never in there. If the sign-in is not completed, all of it disappears.

If you ask for a login code, we store an encrypted fingerprint of the code for at most ten minutes. The fingerprint is marked as used once you have signed in, and is deleted shortly after — at the latest when the code expires after ten minutes. The code is sent to you by email; beyond that email, we never write down the code itself.

Your household. Who belongs to it, each person's residency status, which province you belong to, and which cases and deadlines apply. This is what the service calculates from.

Documents you upload. The content of the documents, file names, file types and timestamps. Documents are stored encrypted and scanned for malware before they become available.

Messages you forward. If you use the email channel, we process the content of the email you forwarded yourself, the sender, the recipient and the time. We do not read your inbox — we only see what you send us.

Conversations with the assistant. Your questions and the answers you receive, together with any images or documents you attach to the conversation. Attachments are deleted as soon as the answer is given, and never end up in the document vault.

Technical data. IP address at sign-in and registration, used to stop abuse. A security log of who opened or deleted which document, and when.

Consent to the terms. Which version you accepted, when, in which language, and a fingerprint of the exact text you were shown.

Why we process it, and on what basis

If you upload a document containing health data or other special categories, we process it only because you chose to put it there. You can delete it at any time.

Artificial intelligence

Parts of the service use a language model to understand documents and answer questions. The part of the text that is needed is then sent to the model provider. We never use your data to train models.

The assistant never gives a binding assessment. It can be wrong, and its answers are not pre-approved by a human. Content published on the public pages, by contrast, is always read and approved by a named editor first.

Who we share with

We do not sell data and we do not share it for marketing. We use sub-processors that process data on our behalf, under a data processing agreement:

• Web hosting — hosting and delivering the pages.
• Database — storing your data, in the EU.
• Language model — interpreting documents and answering in the assistant.
• Sending sign-in codes — your email address and the email containing the

code pass through an email provider. The provider stores the email and its delivery log in the United States for 30 days.

• Email provider — only if you connect Google or Microsoft yourself to send

replies from your own address. We are then allowed to send only, never to read your inbox.

Some of these may process data outside the EEA. Such transfers are made under the EU Standard Contractual Clauses.

How long we keep it

• Account and household: as long as you have an account. Delete the account

and they are deleted.

• Documents: until you delete them yourself, or the account is deleted.
• Attachments in assistant conversations: deleted immediately after the

answer is given.

• Security log: 12 months, because it is protected against traces being

erased.

• Consent to the terms: for as long as we are legally required to be able

to document the agreement. It is your evidence as much as ours.

Your rights

You have the right to:

• know what we process, and get a copy of it,
• have anything incorrect corrected,
• have your data deleted,
• restrict or object to the processing,
• take your data to another service,
• withdraw a consent, without affecting what has already been done.

You exercise these rights by writing to us via the support page. We answer within 30 days.

If you disagree with how we process your data, you can complain to the Norwegian Data Protection Authority, or to the supervisory authority where you live — in Spain that is the Agencia Española de Protección de Datos.

Security

Documents are stored encrypted and scanned for malware. A document that cannot be scanned stays in quarantine rather than being let through. Access to your documents is tied to your household and enforced by the database, not only by the interface. All access and deletions are logged.

Children

Lily&Luna is not made for children, and you must be at least 18 to create an account.

Changes

If we change this notice, we update the version number and the date at the top. If the change is material, we say so in the app.